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Universal Life Church (UCL) ministers lack the requisite qualification of clergymen or ministers of any religion under N.Y. Dom. Rel. Law § 11. The UCL is not an ecclesiastical body of denomination or order. The UCL does not have actual churches or stated meeting places for worship or any form of religious observance, presided over or directed by a person regarded by such group as its minister, whether or not properly ordained, which would vest in such persons the authority to perform marriage ceremonies. UCL ministers' authority rests solely on obtaining in the mail credentials of ministry cards. In other churches ministers are elected or selected by the congregation. The UCL encourages all that subscribe to its one tenet to become ministers. A church which consists of all ministers, and in which all new converts can become instant ministers, in fact has no minister. A minister whose title and status is so casually and cavalierly acquired does not qualify for licensing to marry.
A Universal Life Church (UCL) minister married defendant husband and plaintiff wife. Before the wedding, they executed an antenuptial agreement. The parties cohabited after the marriage for 84 days. Plaintiff wife sought a judgment of divorce, a judgment declaring that the marriage between the parties was a nullity and void ab initio, but sought recovery under the antenuptial agreement. The defendant husband sought a judgment declaring that the marriage, the antenuptial agreement, and the agreement to pay the wife were void. The Supreme Court, Suffolk County, granted plaintiff wife temporary maintenance, directed husband to maintain health insurance for her during the pendency of the action and to pay reasonable health care expenses for treatment not covered by insurance, and awarded wife interim counsel fees. Defendant husband appealed.
Under the circumstances, was the parties’ marriage, antenuptial agreement, and the agreement to pay the wife void?
The court held that the marriage, solemnized by a Universal Life Church (UCL) minister was void. The court noted that the UCL was not an ecclesiastical body of denomination or order, and UCL ministers lacked the requisite qualification of clergymen or ministers of any religion under N.Y. Dom. Rel. Law § 11. The two antenuptial agreements were therefore not valid and could not be enforced by the wife. The parties could be restored to their prenuptial positions without the agreement. Because the parties cohabited for a very short time, the wife owned and operated her own business, had maintained her own residence, and she had already paid her counsel, the court found that her requests for temporary maintenance, medical and dental benefits and interim counsel fees should have been denied on the merits.